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March 4, 2016

AMGA Comments on Proposed Medicare Advantage 2017 Rates, Policies

Alexandria, VA – The American Medical Group Association (AMGA) today submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the Advance Notice of Methodological Changes for Calendar Year 2017 Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 2017 Call Letter.   In its comments on CMS’ proposals and policies, AMGA cited its support for a number of proposed changes to the MA program, while also encouraging CMS to proceed cautiously as it furthers its transition to Encounter Data System (EDS) risk scoring.

“AMGA is pleased to see CMS is accounting for the variation in patient characteristics and demographics in its Medicare Advantage risk-scoring and Star Rating system,” said Donald W. Fisher, Ph.D., CAE, AMGA’s President and Chief Executive Officer.  “However, we remain concerned that CMS is moving too aggressively to base risk scores on Encounter Data.”

CMS is proposing to modify how the EDS is used in calculating risk scores.  After reviewing the proposal, AMGA remains concerned that moving toward a risk score that is more heavily weighted with EDS will further exacerbate already existing problems with accurate EDS reporting.   There are multiple rejection points as data migrates from physicians to provider organizations and on to health plans and purchasers.  AMGA feels that it would be most appropriate to delay any continued move toward risk-scoring weighted heavily toward encounter-based data, and keep in place the current 90% Risk Adjustment Processing System (RAPS) and Fee-For-Service (FFS) and 10% EDS/FFS weighted risk score.  AMGA also recommends that CMS detail in its final notice what current and planned process improvement or system redesign activities the agency will use to assist MA plans and providers that lend confidence that the EDS process is working appropriately.

AMGA is largely supportive of other proposed changes to the MA program, particularly the expected increase in revenue for plan payments.   In addition, AMGA’s comments are supportive of CMS’ proposal to improve the Hierarchical Condition Category (HCC) risk-adjustment model by adding new, specific subgroups to more accurately reflect spending to care for the dual-eligible beneficiary population.  AMGA also appreciates CMS’ efforts to equalize the Star Rating system for MA plans by more accurately accounting for those plans and providers that have a comparatively larger dual-eligible and Low-Income Subsidy (LIS) population.

Read AMGA’s Full Comments.

About AMGA
The American Medical Group Association (AMGA) is a 501(c)(6) trade association representing medical groups, health systems, and other organized systems of care, including some of the nation's largest, most prestigious integrated delivery systems. AMGA is a leading voice in advocating for efficient, team-based, and accountable care. AMGA members encompass all models of organized systems of care in the healthcare industry, including: physician-owned, independent group practices, integrated delivery systems, hospital-affiliated medical groups, independent practice associations (IPAs), academic and faculty practices, accountable care organizations, and high-performing health systems. Approximately 177,000 physicians practice in AMGA member organizations, providing healthcare services for 133 million patients (approximately one in three Americans). Headquartered in Alexandria, Virginia, AMGA is the strategic partner for these organizations, providing a comprehensive package of benefits, including political advocacy, educational and networking programs, publications, benchmarking data services, and financial and operations assistance.